Lead Safe Work Practices: Building Sustainable Capacity National Lead-Safe Housing and Indoor Environmental Health Confe

1. Lead Safe Work Practices: Building Sustainable Capacity National Lead-Safe Housing and Indoor Environmental Health Conference 2002

2. Rachel M. Riley, CET HUD Office of Healthy Homes and Lead Hazard Control Washington, D.C. • John R. Zilka QuanTech, Inc. Arlington, VA

3. Who’s Here?

4. Learning Objectives • After the session attendees will be able to: • Define important terms • List activities requiring LSWP training • Describe HUD’s nationwide training initiative

5. Learning Objectives • List HUD’s recommended LSWP trainer qualifications • Describe the training market • List materials and equipment for LSWP training

6. Background and Regulatory Requirements

7. Accomplishments • 30,000+ individuals trained to date • 780 sessions on LSWP • In almost every state and territory • Certification training • 5 Train-the-trainer trainings for LSWP contract • Approved 12 LSWP curricula • Programmatic training courses and meetings

8. Abbreviations • CFR: Code of Federal Regulations • HQS: HUD’s Housing Quality Standards • LSHR: HUD’s Lead Safe Housing Rule • LSWP: Lead safe work practices

9. Lead Safe Work Practices (LSWP) • General term for set of procedures that reduce potential for lead exposure during a broad range of activities • HUD’s Lead Safe Housing Rule, 24 CFR Part 35

10. Reason and Purpose for LSWP • Reason: Both scientific studies and anecdotal evidence have found a link between traditional renovation practices and blood lead and dust and soil lead. • Purpose: • Protect occupants • Protect interior and exterior environments • Protect workers

11. Types of Non-evaluative Work Mentioned in Title X

12. Basic Federal Requirements • For non-evaluative work • Worker qualifications • Work practice standards, including clearance

13. Lead Safe Housing Rule (LSHR) • 24 Part 35 consolidated all HUD lead requirements • Significant reliance on LSWP • Required by many subparts • Paired with clearance • Rule supports certification required per EPA 402 rule

14. HUD Worker Qualifications • 24 CFR 35.1330(a)(4) • Trained in OSHA hazard communication (29CFR 1926.59) • Supervised by abatement supervisor or trained in lead-safe work practices

15. Safe Work Practices (§35.1350) • Certain methods prohibited • Occupant protection and worksite preparation • Specialized cleaning methods • Required for activities disturbing more than very small amounts of painted surfaces

16. Prohibited Practices (§35.130) • Open flame burning • Machine sanding w/o HEPA exhaust • Abrasive blasting w/o HEPA exhaust • Heat gun over 1100° F • Dry sanding or dry scraping (with limited exceptions) • Paint stripping in poorly ventilated space using a volatile, hazardous substance

17. Activities Using LSWP • Low-level rehabilitation • Ongoing LBP maintenance • Periodic cleaning of dust or debris • Weatherization, remodeling, renovation • Interim controls • Standard treatments • Paint stabilization, repainting • Moderate and “gut” rehabilitation • Abatement

18. Terms • “Lead Safe Work Practices” are used in a wide range of activities • When known or presumed LBP is disturbed in Federally assisted housing, procedures must be used by trades

19. Terms, cont’d. • Not the same as “Interim Controls” • Interim controls are overall methods intended to temporarily reduce lead exposure to lead-based paint hazards (I.e., paint stabilization, lining window troughs with coil stock, covering bare soil). • Lead safe work practices are methods to control and contain dust that are used during interim controls, maintenance work or other activity.

20. “HUD-Approved LSWP Training”

21. Training Required For: • HUD-approved training is required for individuals who perform interim controls: • Treat friction surfaces • Treat impact surfaces • Treat chewable surfaces • Control contaminated soil • Control lead dust hazards • Perform standard treatments • Perform ongoing LBP maintenance

22. Training Required For: • HUD-approved training is required for individuals who: • Perform ongoing LBP maintenance • Treat bare soil • Stabilize paint • Perform regular building maintenance activities or other maintenance or renovation work impacting known or presumed LBP

23. Training Required For: • Paint Stabilization: • Is a type of interim control • Is performed as part of owner’s ongoing LBP maintenance program • Satisfies HUD’s housing quality standards (HQS) inspection requirements • Risk Assessment is not necessary to stabilize deteriorated paint

24. Training Is Recommended For: • Low level rehabilitation ( < $5K/unit) • Disturbance of small amount of old painted surfaces • Volunteer program supervisors (“house captains”) • Explains reasons and processes • Purpose and procedures • Cleaning and clearance

25. HUD-Approval Process • HUD approves curricula, not delivery • Private and public entities have approved courses • List of approved courses is located at: www.hud.gov/offices/lead/lbptraining.cfm

26. HUD-Approval Process • HUD recommends use of existing curricula • HUD has Interim Training Criteria for Course Approval (see handout) • Recommended instructor qualifications • Submittals need to include complete curriculum and all supplemental materials for review and approval

27. HUD’s Recommended Trainer Qualifications • Background in adult education • Train-the-trainer session important • Have you presented to: • Neighborhood groups? • Sunday school? • Work meetings? • Before you train: • Assess your comfort level speaking • Learn from experienced educators

28. Trainer Qualifications, cont’d. • Lead Technical Competence • Risk assessor, Supervisor certification not required • Evaluation and lead hazard control knowledge important • Follow State requirements for LSWP training, if applicable • Understanding of Federal, State and Local Regulations and Policies • Provide State contact information

29. Training Grants Met Community Needs • NCHH grants • Iowa State Fiberoptic Network (ICN) • Health Dept personnel delivered training • Several hundred workers trained • Rural ICN sites • Public Housing Agency staff deliver LSWP training (Iowa)

30. Training Meets Community Needs • Health/Housing Dept partner to develop training (Conn., N. Car.) • Tribes – environmental staff deliver training • Community colleges initiative • Existing deliveries in community colleges (Pennsylvania, Iowa, Md.)

31. Volunteer Programs • Rehabilitation • Up to $5,000 federal assistance per unit • Subpart J of Rule • Use LSWP; no formal training required • “Awareness” of lead hazards and proper techniques

32. Existing Training Sources • Partnerships key • Use Lead Listing as resource • EPA-accredited lead training providers, universities • NETA-certified instructors (CETs) • OSHA Training Institutes/other Env. Health and Safety trainers

33. Curricula and Training Delivery

34. New Training • A brand-new type of training • Not for certification • Provides “Notice of Completion” rather than a “certificate” • No prerequisites • Not OSHA training • Currently only instructor-led; not yet computer-based or web-based • 8 hours duration

35. HUD-Sponsored LSWP Training • Built capacity: 30,000 workers trained by HUD • Two courses were taught by HUD: • HUD’s adaptation of EPA’s Model Course on Renovation and Remodeling • NETA Maintenance Training • Nine other approved courses are available (see handout or web site)

36. HUD-Sponsored Training • Developed capacity quickly • Targeted large and medium-sized cities • Partnered with housing agencies • Outreach and marketing • Attendance increased with participation of local agency • Some Public Housing Agencies and Community Development Agencies sponsored sessions • State lead and training rules covered

37. Common Elements • All HUD-approved courses must cover: • Purpose and limitations of training • Background and health effects • Lead Safe Housing Rule requirements for work practices and clearance • LBP and LBP Hazards • Regulatory overview, worker protection

38. Elements, cont’d. • Prohibited work practices • Containment and dust control • Soil-lead hazard control • Specialized cleaning • Waste handling and disposal • Clearance • Occupant Protection • Test (70% to pass)

39. HUD’s Message • Lead safe work is based on simple concepts – “You can do it!” • Being careful takes longer and costs a little more • Numerous success stories are available • This is not abatement training • This is not a regulations course

40. The “Can Do” Approach • Teach students how to do the “right thing” • Motivate students to do the “right thing” • Focus on WHAT to do; what’s different with lead • Briefly outline OSHA requirements

41. Instructor’s Role • Don’t alter the curriculum except to add state requirements • Avoid opinion, interpretations • Avoids misstatements and misunderstanding • Avoid self-promotion • Acknowledge you don’t know an answer, then find out; no guessing allowed

42. Choosing a Curriculum • Review all model courses • Compare audience needs to HUD training criteria • Presentation of policy issues • Encouraging compliance • Additional OSHA training • EPA requirements

43. Curriculum, cont’d. • Speak or meet with State lead regulator • Receptive to LSWP training? • Is State approval required to teach? • Does model course align with State policy on: • personal protection • work methods • clearance requirements?

44. Curricula, cont’d. • Add State requirements • Does State license non-abatement personnel? Sampling technicians? • Other modifications • Plan course approval procedure, if applicable • Send State courtesy copy of curriculum if no approval procedure

45. Training Issues • Curricula may be “chunked” • Course delivery issues • “Do’s and Don’ts” List from HUD • Mission Statement • Marketing advance time (no shows)

46. Training Impacts HUD does not regulate courses regarding: • Schedule • Evening or weekend classes permitted • May divide content into smaller or shorter segments • Training location and access • Can use housing or health agency facility • Can accept in-kind contributions • Try to reduce travel distances

47. Teaching Regulations • The most common pitfall • Do your homework • Keep current on changes • Avoid complicated discussions of rules • Will absorb precious time and derail class • Refer to Interim Criteria for content items

48. Team Teaching • Some lead experts may be willing to participate on training team: • Childhood Lead Poisoning Prevention Program Representatives • Health Department personnel • HUD Lead Hazard Control Grantees • Sections on technical or health issues

49. Equipment & Props • Plastic sheeting • Duct tape • Spray bottles • Rags • Disposable suit • Buckets • HEPA vacuum vs. HEPA-filtered vacuum • N-100 respirator

50. So what did we learn? - 1 • HUD’s initiatives are a “drop in the bucket” to what’s needed • Lot’s of lead related misnomer • Need to regionalize the training offerings to cover all the players • Need to be more customer conscious i.e. schedule, segmented sessions